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All About Canada Revenue Agency

The Canada Revenue Agency's disclosure program always helps taxpayers to willingly reveal unreported income. 

The program ensures that a taxpayer who voluntarily discloses previously unreported income will not be prose­cuted for tax avoidance and will not have any formal penalties required if the Agency's  program conditions are met. You can browse to know more about the  Canada Revenue Agency.

The Agency's four program conditions are as follows:

(1) The disclosure must be voluntary

(2) The disclosure must be complete

(3)The disclosure must include the application, or potential application, of a penalty

(4) The declaration must include information that is at least one year past due.

In many cases, the Minister will not apply his discretion to accept a taxpayer's disclosure under the program citing any type of implementation action. 

The Agency appears to have defined enforcement action as any real or contemplated, direct or indirect, an action that could have published the information that the taxpayer sought to disclose under the Program. 

Cases applied for a legal review of the Minister's decision to not exercise his option to accept program disclosure under the audit process. Authority argued that the agency's alleged enforcement action was not sufficiently linked to the subject disclosure. 

Counsel for the respondent submitted that the Minister's decision was right on the basis that the agency initiated an audit of a corporation with which audit company was associated and that the audit constituted enforcement action that would have leaked the information that lies under the program.You can navigate to this website in order to get more information about the audit process.


The court noted that the respondent's argument did not appear to be supported by any evidence or legal opinion capable of establishing that the audit would have, in fact, uncovered the basic information. 

In these circumstances, the court asked counsel for the respondent to explain how the agency would have supposedly uncovered the information. 

In response, counsel for the respondent posted that that mere mortal would find it difficult to explain the whole process of a tax collector.